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Home My WebLink About08-6492 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF SUSAN J. ADAMS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JEFFREY A. ADAMS, : NO. 08 - In yea CIVIL TERM Defendant : IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF SUSAN J. ADAMS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW JEFFREY A. ADAMS, : NO. 08 - `f 9 Z CIVIL TERM Defendant : IN DIVORCE COMPLJNT IN DIVORCE PURSUANT I ECTION 330101 OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Susan J. Adams, an adult individual residing at 2143 Newville Road, Carlisle, Cumberland County, Pennsylvania 17015. 2. The defendant is Jeffrey A. Adams, an adult individual residing at 129 Walnut Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on July 29, 1989, in Cumberland County, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. 2008 /" ?? Susan J. Adams, laintiff WOLF & WOLF r O Q 2008 BY: ' STACY B. OLF, ESQUII Supreme Court ID #88732 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff ?IJ w w t? c N r. ? c.? J rn STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF SUSAN J. ADAMS, Plaintiff V. JEFFREY A. ADAMS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0.08 - CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. GS. Section 4904 relating to unsworn falsification to authorities. -312008 Susan J. Adams, P ' tiff ?7 r"1 2:- _ y +l J .? _ STACY B. WOLF, ESQUIRE ATTORNEY ID NO. BV32 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF SUSAN J. ADAMS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. JEFFREY A. ADAMS, Defendant : CIVIL ACTION - LAW : NO.08 - L0492- CIVIL TERM : IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotarys Office, which list is available to me upon request. C Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. 2008 Je ey A. Adams, Defendant cz;l rp, q STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 M7) 241-4436 ATTORNEY FOR PLAINTIFF SUSAN J. ADAMS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. JEFFREY A. ADAMS, Defendant CIVIL ACTION - LAW : NO.08 - LjU 92 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICE I, Jeffrey A. Adams, certify that I am the defendant in this matter. Furthermore, I hereby certify that on 2008, I received a certified copy of the divorce complaint filed in this action. 2008 A. A ams fendant ant ?J "? ??. {> ? V fir; : ? ??; :' r?= . s r '°. ?: , ':. ,`a,s.; -?, -.mss . , s? ? `? a ? _? STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ?r 7JIDA i i Fm r: qz ATTORNEY FOR PLAINTIFF SUSAN J. ADAMS, : IN THE COURT OF COMM N`-PtEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. JEFFREY A. ADAMS, Defendant CIVIL ACTION - LAW NO. 08 - 6492 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about October 31, 2008 and served upon defendant on or about November 3, 2008. 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of the service of the complaint. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. 2010 SUSAN J. ADAMS SUSAN J. ADAMS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JEFFREY A. ADAMS, : NO. 08 - 6492 CIVIL TERM Defendant : IN DIVORCE' WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. 7-11-16 , 2010 SUSAN J. AD STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF ThL 2DI0 AUG- J I Nil 1: 42... It?•?SUSAN J. ADAMS, : IN THE COURT OF?COMMO ,'PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. JEFFREY A. ADAMS, Defendant : CIVIL ACTION - LAW : NO. 08 - 6492 CIVIL TERM : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about October 31, 2008 and served upon defendant on or about November 3, 2008. 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. /g2010 JE dRE+YkADAMS SUSAN J. ADAMS, V. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA JEFFREY A. ADAMS, Defendant : CIVIL ACTION - LAW NO. 08 - 6492 CIVIL TERM IN DIVORCE C) i 9 Owl •? w W a? 1^ T J? 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. f)? ?Z .2 (0 , 2010 AV r J F R A. ADAMS =ice STACY B. WOLF, ESQUIRE ATTORNEY II) NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF SUSAN J. ADAMS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JEFFREY A. ADAMS, : NO. 08 - 6492 CIVIL TERM Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: decree: Please transmit the record, together with the following information, to the court for entry of a divorce Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about November 3, 2008, defendant was served with a certified copy of the divorce complaint via regular mail. (See Acceptance of Service previously filed November 4, 2008) 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: August 4, 2010. By the defendant: August 4, 2010. (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: N/A. 4. Related claims pending None 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A. (b) Date plaintiff's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: August 11, 2010. Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: August 11, 2010. August / 2010 - STACY B. LF Attorney fo laintiff Susan J. Adams V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeffrey A. Adams NO. 2008-6492 DIVORCE DECREE AND NOW, uSt?`?, it is ordered and decreed that Susan J. Adams , plaintiff, and Jeffrey A. Adams , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None By the Court, * A ?,a Attest: J. Prothonotary O\ i A j 40 qwo -10